Cited by
Opinions in Minnesota that cite Sanchez v. State, 816 N.W.2d 550.
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Robert Ian Agarano v. State of Minnesota
Minn. Ct. App. 2026
For these purposes, a postconviction claim arises “when the petitioner knew or should have known that he had a claim.”
- State of Minnesota v. Rebecca Lee Treptow Minn. Ct. App. 2026
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State of Minnesota v. Rebecca Lee Treptow
Minn. Ct. App. 2026
A claim “arises” when the petitioner “knew or should have known of the claim.” -60 (Minn. 2012).
- Jacob William Kinn v. State of Minnesota Minn. Ct. App. 2026
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Jacob William Kinn v. State of Minnesota
Minn. Ct. App. 2026
This claim accrues “based on an objective ‘knew or should have known’ standard.”
- State of Minnesota Office of the Attorney General Minn. 2026
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State of Minnesota Office of the Attorney General
Minn. 2026
We generally “have no power to extend or modify statutory limitations periods.”
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In re the Matter of: Femi Joseph Daramola v. the Commissioner of Human Services, et al
Minn. Ct. App. 2025
-61 (Minn. 2012) (declining to reach the question when the appellant did not establish entitlement to the equitable relief).
- Travis Clay Andersen v. State of Minnesota Minn. Ct. App. 2025
- Travis Clay Andersen v. State of Minnesota Minn. Ct. App. 2025
- State of Minnesota v. Timothy Dustin Johannes Minn. Ct. App. 2025
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Richard Preston Blackwell v. State of Minnesota
Minn. Ct. App. 2025
And this exception relates to the “reason the petition was filed after the [two]-year time limit in subdivision 4(a), not the substantive claims in the petition.”
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Eugene and Sandra Alexander, et al., Chris Beck, et al v. Baker Tilly US, LLP
Minn. Ct. App. 2025
The second type of tolling Minnesota recognizes is equitable tolling, which, under certain circumstances, “allows a court to consider the merits of a claim when it would otherwise be barred by a statute of limitations.”
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Russell Vincent Winbush v. State of Minnesota
Minn. Ct. App. 2025
This exception relates to the “reason the petition was filed after the [two]-year time limit in subdivision 4(a), not the substantive claims in the petition.” -36 (Minn. 2021) (stating that the interests- of-justice exception “focuses on why the petition was filed after the [two]-year time limit” and that the petitioner “must allege an injustice that caused the delay in filing the petition” (quotation omitted))
- Albert George McIntosh v. State of Minnesota Minn. Ct. App. 2024
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State of Minnesota Office of the Attorney General v. Madison Equities, Inc.
Minn. Ct. App. 2024
by some ‘paramount authority’ or by situations arising out of ‘invincible necessity’” from commencing suit.10 (quoting St.
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Minn. 2024
For instance, the court addressed when the limitations period for a petition brought under the postconviction statute, Minn. Stat. § 590.01 (2010), begins to run.
- Victor Cortez Shelton v. State of Minnesota Minn. Ct. App. 2024
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Scott Marlin Morey v. State of Minnesota
Minn. Ct. App. 2024
The interests of justice provide a petitioner with an exception to the two-year statutory time-bar only if the injustice relates to the reason the petition was filed after the time limit and the injustice caused them “to miss the primary deadline.”
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Travis Clay Andersen v. State of Minnesota
Minn. Ct. App. 2024
See Sanchez v. State , d 550, 557 (Minn. 2012).
- Carlos Heard v. State of Minnesota Minn. Ct. App. 2024
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Carlos Heard v. State of Minnesota
Minn. Ct. App. 2024
exception relates to the reason the petition was filed after the two-year time limit, not the substantive claims in the petition; in other words, “the interests-of-justice exception is 15 triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), not the substance of the petition.”
- Michael James Rye v. State of Minnesota Minn. Ct. App. 2024
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Michael James Rye v. State of Minnesota
Minn. Ct. App. 2024
d 550, 560 (Minn. 2012).
- Howard William Amos v. State of Minnesota Minn. Ct. App. 2024
- Howard William Amos v. State of Minnesota Minn. Ct. App. 2024
- Edbert Neal Williams v. State of Minnesota Minn. 2024
- Edbert Neal Williams v. State of Minnesota Minn. 2024
- Ronald Lewis Greer v. State of Minnesota Minn. 2024
- Ronald Lewis Greer v. State of Minnesota Minn. 2024
- Kawaskii Antonio Blanche, Minn. 2023
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St. Louis County Gildea, C.J. Tyrone James White, Appellant, vs.
Minn. 2023
But the exception “relate[s] to the reason the petition was filed after the 2–year time limit in subdivision 4(a), not the substantive claims in the petition.” Caldwell, d at 141.
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A22-0300
Minn. 2023
If applicable, “[t]he doctrine of equitable tolling allows a court to consider the merits of a claim when it would otherwise be barred by a statute of limitations.” Sanchez v. State , (discussing tolling under Holland).
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, A22-0057
Minn. 2022
see also Andersen III, d at 428 12 (Minn. 2018).
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Orlando Omar Castillo v. State of Minnesota
Minn. Ct. App. 2022
See Sanchez, (“The determination of when [the petitioner]’s interests-of-justice claim arose is a question of fact.”).
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Lincoln Lamar Caldwell,
Minn. 2022
(Minn. 6 We issued our opinion in Caldwell’s direct appeal on August 11, 2011, and his conviction became final on December 10, 2011.
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John Stephen Woodward v. State of Minnesota
Minn. Ct. App. 2022
4(c); -58, 560 (Minn. 2012) (holding that claim “arises” when claimant “knew or should have known that [they] had a claim”).
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State of Minnesota v. Shawn Douglas Hager
Minn. Ct. App. 2022
d 550, 556 (Minn. 2012).
- Jason Charles Cibulka v. State of Minnesota Minn. Ct. App. 2022
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Jose Antonio Martinez-Fuentes v. State of Minnesota
Minn. Ct. App. 2022
In Sanchez v. State, the supreme court explained that “the interests-of-justice exception is triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), and not to the substance of his petition.” (M inn.
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Matthew William Edwards v. State of Minnesota
Minn. Ct. App. 2022
Even when an exception to the two -year deadline in subd ivision 4(a)(1) applies, however, “[s]ubdivision 4(c) creates the additional requirement that a petition invoking an exception provided in [4](b) must be filed within two years of the date the claim arises.” Sanchez v. State , (quotation omitted).
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Shane Paul Schultz v. State of Minnesota
Minn. Ct. App. 2022
Sanchez v. State , d 550, 558-60 (Minn. 2012).
- John Steven Martin, Minn. 2022
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Terrance James Bowers v. State of Minnesota
Minn. Ct. App. 2021
4(b)(5) (2020) ; see also Hooper v. State , (holding that an interests -of-justice claim “must relate to an injustice that delayed the filing of the petition, not to the substantive merit of the petition”); Sanchez v. State , (same).
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Aka Lawrence Fualefeh v. State of Minnesota
Minn. Ct. App. 2021
d 550, 552 (Minn. 2012).
- Kenny Lee Reed, FKA: Gordon David Reese v. State of Minnesota Minn. Ct. App. 2021
- Jose Santoya Juarez v. State of Minnesota Minn. Ct. App. 2021
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Syrrome James Phylip Moos v. State of Minnesota
Minn. Ct. App. 2021
Such a claim arises when the petitioner “knew or should have known that he had a claim.”
- A20-0206 A20-0228 A20-0229 Minn. 2021
- S’Emaj Avyiair Okongwu v. State of Minnesota Minn. Ct. App. 2021